GSI New Betatron Lead Shielded Door

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Docket 140 General Steel Industries:

Addendum #1 to 2-28-2012 Submission

by Daniel W. McKeel, Jr., M.D.

GSI SEC-00105 Co-Petitioner

March 11, 2012

A. Comments Concerning NRC FOIA 2010-0012 Document ML093451450.pdf

Dated November 4, 1968, and the New Betatron Lead Shielded Door:

Background and Introduction

This submission to Docket 140 for General Steel Industries (“GSI”) AWE site

located at 1417 State Street in Granite City, Illinois, should be considered an

ADDENDUM to my Docket 140 submission posted on the DCAS website on 2/28/12.

As noted in the previous critique, David Allen in his January 2012 white paper on

GSI Betatron Operations, cites evidence from 1971 and 1968 that the new Betatron

facility had a lead shielded door to the railroad tunnel entry and exit point. He cited NRC

FOIA 2010-0012 evidence from documents that co-petitioner McKeel had gotten from

the NRC and first brought to the attention of the ABRWH, its TBD-6000 working group,

NIOSH and SC&A. The point was made in the Dan McKeel 2/28/12 critique that 1968

and 1971-72 dates were after and outside of the covered period ended at GSI on

12/31/1966. The fact of a lead shielded double leaf door in the New Betatron facility,

even if it were true, would therefore have no bearing on the SEC-00105 NIOSH defined

class. Nor, we argue, would it have any bearing on GSI dose reconstructions, because

the EEOICPA Act and OCAS-IG-003 mandate that NIOSH consider only non-AEC work

related sources such as the GSI Betatrons within the 1953 to June 1966 GSI covered

period of time. I argue against accepting that lead shielding was ever in place (DCAS).

Addendum document NRC ML9093451540, features are as follows:

1. The PDF document is a letter from H.B. Norris at GSI to Mr. James C. Malaro,

Isotopes Branch, Division of Materials Licensing, US Atomic Energy Commission,

Washington, DC 20545, and is dated November 4, 1968.
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2. The last page of the PDF is numbered “Page 4” but the file consists of only

three pages. Therefore, one page is presumed to be missing. A copy of the file PDF file

I downloaded from the NRC website on 3/4/12 is therefore attached to and made part of

this Addendum document.

3. Mr. Norris identifies himself as “Manager of Quality Control” in the November

4, 1962 letter that is on GSI letterhead. Of note, and for the record, the address block

for this letter is:

 “Castings Division, 1417 State Street, Granite City, Illinois. 62040.

 618 • GL 2-2120.”

McKeel previously learned from Chris Passmore and Emily Quirke at RS

Landauer that Mr. Norris was head of the GSI film badge program that started in 1964

under Mr. Norris’ direction.

4. Page 2 of the November 4, 1962 Norris-GSI to Malaro-AEC letter is a drawing

of the GSI New Betatron building that is reproduced here on page 3 of this document.

The drawing has the following features: (a) Many of the legends are typed, while the

annotations are hand drawn and lettered; (b) this is a two dimensional floor plan only;

there are no side wall elevations shown; (c) of most direct relevance to this Addendum

is a hand lettered annotation along the middle of the left that reads:

“Double-Leaf Door

Bottom Leaf - 7’0”

High - Lead Shield”

Note there is no drawn representation of the door or the lead shield itself. There is

simply a wavy line and arrowhead pointing to a space that is spanned by a hand drawn

“{“ type of bracket; (d) the door area is at the end of a 27 ft. long area bounded by walls

that are described as “Concrete Block Walls - Mortar Filled 25’0” High”; (e) area (d) is

different from the area labeled as (typed in) “Work Area For Co 60” that is bounded by

walls three of which as annotated as “9’0” Sand” and one wall designated as “10’0”

Sand” (outer dimensions “97’0” by 71’0”), an area that is described overall as having

“Sand-Filled Walls 25’0” High; (f) the area labeled “Control Room” and the concrete

block wall of the tunnel on the same side are shown as being thinner than the opposite
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tunnel concrete block wall. The control room door that Mr. Ramspott and Dan McKeel

have provided photographs of from 2006 to be a thin steel door was drawn as such.

(g) the Co 60 source control cables passed through the thin wall next to this door.

Legend. New Betatron Building drawing 06444 labeled --General Plan-- New Betatron G.S.I. 11-4-68

Note the source is drawn as being controlled by a 22’0” long cable, and the source is

shown with two apparent side wheels, as has been testified by many GSI workers who

said they used an 80 Curie GSI Co-60 during the last 3 years of the covered period

(1964-66). The idealized position of a casting (Co 60 NDT target) is shown.

NIOSH or SC&A have presented no evidence that the lead shield ever

existed on the New Betatron exit/entry door to the railroad track tunnel. Separate

McKeel and Ramspott September 2006 photographs and 1992 ORNL-DOE cleanup

photos clearly show the New Betatron door to be double-leaf with vertical metal ribs on

the lower door panel and no lead shielding. The worker affidavit testimony is
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unanimously to the contrary, that there were no lead shields at anytime for the Old and

New Betatrons, including years 1968 to 1973 when GSI was still operating.

B. Status of the David Allen and DCAS Path Forward Initiative for or GSI

Background and Introduction

By October 2010 the TBD-6000 work group had been deliberating about revising

Appendix BB to Battelle TBD-6000 for three and a half years. The work group also had

been discussing the NIOSH evaluation report for GSI SEC-00105 for a full two years by

then. SC&A had reviewed both documents and issued numerous, only partially resolved

formal Findings related to each of them. The work group was scheduled to convene its

next meeting on October 12, 2010.

In a move that was a total surprise to co-petitioner McKeel, just prior to the

upcoming work group meeting, David Allen and DCAS issued a white paper document

dated October 2010 and titled “A Path Forward for GSI.” In it, the unresolved Appendix

BB and SEC-00105 SC&A Findings were “explained away” by stating the issues would

be addressed in a new “Path Forward” plan by NIOSH. Very importantly, this document

proposed to develop “new exposure models” that would “consolidate” all of the new

information provided to NIOSH from the past years.

One section of the October 2010 Path Forward document explicitly indicated

that six (6) unresolved SEC issues would also be addressed. This SEC evaluation

issue review has not materialized in the ensuing 16 months. Specifically, the

following passage was part of the October 2010 Allen Path Forward for GSI proposal:

 [quote Oct. 2010 white paper on SEC path forward here]

Page 8 of 9 (begin quote)

Evaluation Report Issues

The chairman of the working group also asked that issues 1, 2, 3, 5 and 6

from the Evaluation Report review be addressed.

Issue 1 – SC&A pointed out that several incidents were verbalized by

workers and without film badge data, other incidents could be unknown.

The handling of incidents is discussed in the Co_60 section of the path

forward. A preliminary review indicates a consistent frequency through

the years that monitoring data is available.
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Issue 2 – SC&A pointed out that betatron operators removed their

badges when leaving the betatron building but scenarios exist where they

could have been exposed outside that building. The path forward

addresses developing new exposure scenarios based on all the

information that has come to NIOSH since the appendix was approved.

Issue 3 – SC&A indicated that the amount of uranium work is unknown

prior to 1958 and that there is no record of the type of radiography

sources used at GSI. The path forward addresses developing new

exposure scenarios based on all the information that has come to NIOSH

since the appendix was approved. This includes information about the

radiography sources used at GSI.

Page 9 of 9

Issue 5 – SC&A indicated there is no agreement between the appendix

model and the film badge results. The path forward addresses developing

new exposure models and reconciling them with the film badge

data.

Issue 6 – SC&A points out again that there are other exposure scenarios

not addressed in the appendix. The path forward addresses developing

new exposure scenarios based on all the information that has come to

NIOSH since the appendix was approved and using those scenarios to

revise the dose estimates.

(End quote)

Then, a specific list of NIOSH “deliverables,” that is work products that

(presumably) would meet the October 2010 Path Forward goals emerged. That

schedule is reproduced below. The second major thesis of this petitioner section is that

all ten new models have not been fully covered in the ensuing David Allen and

DCAS methods white papers dated October 2011 covering GSI portable sources

and dated January 2012 covering GSI Betatron operations.

 [list the 10 proposed exposure models here]

--------------------------------------------------------------------------------------------------

In a message dated 5/16/11 12:38:19 PM, pl.ziemer@comcast.net writes:

I have now received word that the following items will be delivered to the

Work Group as shown in the schedule below:

1. Develop exposure model for Ra radiography 7/29/2011

2. Develop exposure model for St. Louis Testing radiography 7/29/2011

3. Develop exposure model for portable x-ray radiography 7/29/2011

4. Develop exposure model for Co-60 radiography 7/29/2011

5. Develop exposure model for New Betatron 12/30/2011

6. Develop exposure model for Old Betatron12/30/2011

7. Develop exposure model for air activation from betatron 12/30/2011

8. Develop exposure model for uranium activation from betatron

 12/30/2011

9. Develop exposure model for steel activation from betatron 12/30/2011
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10. Reconcile dose estimates with dose records 12/30/2011

[McKeel note: I have added numbers for future reference]

We will need to allow some time for SC&A to review the materials, so I

will expect to have the Work Group meet in late August to consider the

July 29 deliverables on the list.

Regards,

Paul Ziemer

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Co-petitioner McKeel assumed therefore that ten separate new white papers

would follow, each one addressing one of the ten exposure models. It was not clear

whether the ten new models would address only Appendix BB issues alone, or would

they also address SEC unresolved issues. Mr. Hinnefeld’s response made it very clear

the ten models addressed only Appendix BB. Further, he stated that NIOSH had “no

plans” at that time to reissue its evaluation report and recommendation to deny SEC00105 for GSI.

The question then arises, did NIOSH actually deliver these ten new models in the

David Allen October 2011 and January 2012 white papers that followed? The answer is

“No, not completely.” While the October 2011 Allen white paper does address models

1 through 4 inclusively to some extent, NIOSH failed to adhere to their own guidance

OCAS-IG-003 and calculate all doses with sufficient accuracy for all workers in all jobs

at GSI as is required by the Act and by OCAS-IG-003.

The specific requirements not fulfilled by the October 2011 paper are as follows:

Model #1, Radium-226 radiography. We first show by existing former worker

affidavit testimony and new evidence to be presented in section C of this addendum that

the Radium-226 NDT work occurred both inside and outside the 6 building “Radiograph

Room” that is clearly shown on a newly obtained and detailed 1957 GSI plant map. The

Radiograph Room was modified in June/July of 1962, and thereafter was referred to in

the GSI AEC by-products license material from the NRC (McKeel FOIA 2010-0012) as

the “Building 6 radiography facility.” The Radiograph Room within bldg. 6 on the 1957

GSI general map and the Bldg. 6 Radiography facility of 1962 and later vintage were the

same structure with temporal modifications.
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The new 1957 GSI map was obtained from the current owner of 6 building by site

expert John Ramspott in March of 2012. See map title block and Radiograph Room

Bldg. 6 reproduced below:

LEGEND. From General Map of General Steel Castings, Granite City, IL Plant 1957

Second, evidence cited in section A proved that the inner steel shielding, entry

door, and (possibly) reinforced concrete block walls, were not put in place in the 6

building radiography facility until June/July 1962, with the advent of an impending GSI

source term license from the AEC for two 0.5 curie Cobalt-60 NDT gamma sources.
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Therefore, it becomes apparent that isotope operators of the two Radium-226

sources who used the fishpole technique during and prior to 1962 were not protected by

lead or steel plate shielding in the 6 building inner Radiography facility/room as David

Allen states repeatedly they were in his recent white papers. The precise date the inner

concrete building radiography facility was built is not known, but the evidence cited

above indicates it must have been there as of January 1957. A now deceased

supervisor at GSI (Gillum Burgess), who is well known to the Board and to SC&A and

NIOSH, stated that radium was used for NDT examination of railroad car trucks “before

the AEC x-ray work was started,” which was in 1953. We can as a result of this

statement infer that the inner GSI building 6 radiography facility may have existed in

some form, that was modified after June/July 1962 when Co-60 replaced Ra-226 for

NDT work at GSI, through the entire GSI covered period (1953 to June 1966).

Model #3. Develop exposure model for portable x-ray radiography.

The Allen October 2011 white paper does not fulfill “all” and “must” criteria to

calculate doses with sufficient accuracy for the three industrial roughly 250 x-ray

machines known to exist during the covered period at GSI. NIOSH has no basic

knowledge of which workers or how many workers used these machines a,d how often

and for what specific purposes. Hence, they could not, and did not, calculate external

doses for the portable x-ray units. This failure to calculate is both an Appendix BB and

OCAS-IG-003 all and must issue, and a SEC-00105 issue.

Model #4. Develop exposure model for Co-60 radiography.

NIOSH and Allen did model exposures for the two small Co-60 gamma sources,

and excluded from the model the “large” 80 Curie Co-60 source that at least six GSI

former workers said in affidavits was used by them and owned by GSI in 1964 through

1966. NIOSH gave greater weight to the AEC source license GSI obtained in 1968 that

was part of NRC 2010-0012 in the documents that co-petitioner McKeel first obtained by

the FOIA mechanism. McKeel, John Ramspott site expert and Betatron operator eye

witnesses thus all support the presence of an 80 Curie GSI-owned Co-60 NDT gamma

source that must be addressed for the covered period 1964-66 under OCAS-IG-003 and
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be included in total dose assigned using Appendix BB as primary guidance for dose

reconstruction.

Exposure models #5 through #10 were supposed to be addressed in the second

Allen white paper dated January 2012. Again, the question arises, were all six models

actually delivered? Again, the answer in the co-petitioner’s view is NO, they were not.

Model #5. Develop exposure model for New Betatron.

The January 2012 Allen white paper deals almost exclusively with the new

Betatron. Essentially he admits not having any actual monitoring data for the New

Betatron except the R/min of the donut tube. There is no New Betatron Building

radiologic survey data that reflects actual operation of the 25 Mev X-ray machine during

uranium or steel castings NDT work.

Previously both NIOSH and SC&A used different computer codes to simulate

Betatron photon doses. NIOSH used Attila code and SC&A used MCNPx transport

modeling code. The results disagreed both qualitatively as to peak dose years and

quantitatively as actual dose delivered. Most importantly, both estimates diverged from

Betatron operator film badge readings for 1964-66, the only real data available to test

the validity of the modeled data, by 10 to 12-fold as was reviewed at the November

2010 TBD-6000 work group meeting. Inexplicably, Mr. Allen fails to include those

disparate and divergent dose estimations in the January 2012 analysis.

Instead, Mr. Allen choses to compare film badge readings to an irrelevant

gamma survey made by non health physicist, non-certified GSI radiographers in 1971

using an 80 Curie GSI cobalt-60 source. The petitioners believe this analysis is not in

any way germane to Betatron Operations. Besides that, the analysis falls outside the

covered period. We know certain modification were introduced in the New Betatron

building in 1968 and 1971, including replacement of the roll-up steel door with a double

leaf door guarding the railroad tunnel leading to Building 6.

In the October 2010 Allen “Path Forward For GSI” document, on page of 9,

Mr. Allen makes the following statement concerning the 80 Curie Co-60 source:

(start quote)

From the above information some fundamental concepts can be

expressed, which can be applied to modeling exposure at GSI. This

includes:
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(portion omitted...)

The 80 Ci Co_60 source was purchased after the end of the contract

period in 1966 and so exposure from this source is not covered under

EEOICPA. (emphasis added)

(end quote)

Thus in this section of the October 2010 document Mr. Allen negates the validity

of using the same Co-60 source he proposes using to model New Betatron radiation

fields in the Path Forward. This is self-contradictory and scientifically unsound

approach, and the petitioners believes the 1971 large C0-60 source modeling should

not be allowed as a substitute for developing a new, more accurate model of the New

Betatron 25 Mev x-ray source that has a widely different energy output spectrum in the

emitted beam, a wildly different beam contour (narrow for the Betatron, nearly-spherical

for the Co-60 source. Also, 15% of the Betatron beam is neutrons whereas no neutrons

are emitted from a pure Co-60 source. The two sources are thus quite dissimilar.

The petitioners believe the fact that Mr. Allen’s inability to develop a new

model for the GSI New Betatron is a direct acknowledgement that such doses

cannot be reconstructed with sufficient accuracy, and should be regarded as

strong evidence for overturning NIOSH’s recommendation to deny SEC-00105.

In addition, Mr. Allen has used the flawed assumption that the New Betatron

double leaf door contained a 7 ft. high lead shield on the lower panel that was in place

during the covered period. The petitioners have shown in this critique and its two

addenda there is no evidence the lead shield was in place. To the contrary, DOE/ORNL

photos in 1991 and petitioner and site expert photos from September 2006 show that no

lead shield was in place on the vertical ribbed steel double door.

Between 1964 and 1966, the exit tunnel containing the New Betatron railroad

tracks running into 10 building was enclosed by a red steel roll up door that we have

shown photographs of as having been moved by 2006 to close off the break area entry

from the New Betatron where the railroad tracks entered 10 building. Thus, the modeled

scenario Mr. Allen uses for the New Betatron was not valid for the relevant covered

period (1963-66) when the New Betatron was employed at GSI doing AEC uranium

NDT work.
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Model #6. Develop exposure model for Old Betatron.

No new or revised exposure model for the GSI 24 Mev Old Betatron particle

accelerator was developed or presented in the Allen-DCAS January 2012 as was

supposed to be delivered as a work product by the October 2010 Allen Path Forward for

GSI document. The last line on page 30 indicated that doses from the New Betatron

would be considered to be bounding. However, this statement by itself surely does not

constitute a “new model.” Nor is it reasonable to equate the Old and New Betatron

machines or buildings with one another. They were built ten years apart for example by

different contractors. The Old Betatron facility and machine are known from GSI 1951-

52 Board minutes McKeel and Ramspott obtained from the Missouri Historical Society

in St. Louis that the Old Betatron building, the unit itself and other GSI equipment and

buildings were “government owned.” The government, we learned, tried to give the Old

Betatron building and x-ray unit to GSI, but the Board refused to accept this gift. In

contrast, the New Betatron building was owned by and built in 1963 by GSI.

NIOSH has no (zero) actual monitoring data of any kind, external (film badges,

air or area monitoring, neutron data) or internal (urine uranium bioassays) for Old

Betatron operations during the 1953-63 covered period of operations before the New

Betatron was moved from the GSI Eddystone Division to Granite City, Illinois. TBD-6000

is insufficient to make these calculations due to the “unique nature of GSI,” as was first

admitted by former OCAS Director Larry J. Elliott in a letter mailed to the Ramspotts

dated September 2005.

We also know that the two Betatron buildings differed from one another

structurally as did the two Allis-Chalmers built Betatron particle accelerators including

the output of the donut tubes as documented by Jack Scheutz, a Betatron service

person and paid consultant under contract to NIOSH. It is NIOSH’s responsibility to

prove by written documentation that the Old and New Betatron facilities and machines

were identical in order to divest the EEOICPA implementing agency of the necessity of

characterizing delivered external and internal and skin doses from each machine in their

own facility and separately from one another. This was not done in the January 2012

Allen-DCAS GSI white paper.
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NIOSH has also not adequately factored in leakage radiation and internal

component activation, apart from the electron target, from the unshielded industrial

1952 era Allis-Chalmers 24 to 25 Mev Betatrons. The petitioners provided peer

reviewed journal articles that proved such leakage and activation pathways exist that

have been essentially ignored in NIOSH and SC&A technical reports. McKeel outlined

these additional sources of Betatron dose in detail in his critique and review of Appendix

BB which is posted on the DCAS website under NIOSH Docket 140 for GSI. The

NIOSH rebuttal to the McKeel critique is also published in the same place.

Again, OCAS-IG-003 requires that doses from all radiation sources must be

determined with sufficient accuracy for dose reconstruction purposes. The ten new

exposure models, including model #6, were expressly targeted at revising Appendix BB.

Apparently, judging from the fact that NIOSH failed to deliver a new exposure model for

the GSI Old Betatron in the January 2012 Allen-DCAS white paper, the petitioners

conclude that NIOSH was unable to determine doses from this source with sufficient

accuracy. This is an SEC issue that argues for the Board approving SEC-00105. It also

argues for NIOSH needing to revise and change its recommendation to from denial to

approval of SEC-00105.

Model #7. Develop exposure model for air activation from betatron.

An exposure model was presented to be considered by the Board and SC&A.

Model #8. Develop exposure model for uranium activation from betatron.

This work product, a new exposure model for uranium, utterly fails to take into

consideration, that is ignores, almost all of the newer information the petitioners, site

experts and former GSI radiographers workers provided to NIOSH, the TBD-6000 work

group and full Board, and to SC&A beginning in 2005 with the Ramspott GSI work book.

Some of the new facts that NIOSH failed to incorporate into a new uranium exposure

model, or into Rev 1 of TBD-6000 for that matter, are as follows:

(a) We produced evidence that both the Destrehan Street and the Weldon Spring

Feed Materials Plant operations of the Uranium Division of Mallinckrodt Chemical

Works (“MCW”) delivered not only “Betatron slices” to GSI but also, at various times

intact uranium-238 ingots and dingots (derby melt process, single step ingot process

patented by MCW).
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(b) We produced written and photographic evidence that the major purpose of

NDT activities contracted by the AEC and MCW to GSI was examining intact ingots and

dingots to precisely delineate the interface between the outer magnesium-hexafluoride

“crust” left over from the heating “bomb” and the underlying pure uranium. The crust had

to be removed by vertical lathes and the pure uranium core was very valuable. NIOSH

and SC&A both presume, incorrectly without nay refutation of our evidence, that the

sole uranium NDT work at GSI was done to slabs and slices to define structural voids

and fractures. This is not the case.

(c) NIOSH has neglected to calculate exposure scenarios for all the various

people who had to handle the 3,000 pound 18 inch diameter by 2 foot long ingots and

dingots on the way to the Old and New Betatron facilities. The paths and amount of

handling uranium slabs and ingots and dingots differed between the two Betatron

facilities.

(d) NIOSH has not delineated all of the types of personnel who handled the

uranium that included chainmen, rail road operators, workers near the transport path

and storage locations (that themselves are not precisely known), and personnel who

stored the materials at GSI (the uranium and shots records and x-ray film was not

returned to MCW immediately).

(e) NIOSH has no shot records, shipping manifests, and x-ray reports for GSI

uranium NDT records. All it possesses is a set of MCW-AEC to GSI purchase orders

that cover 1959 through the end of the covered period in 1966. These are insufficient to

establish with any degree of accuracy the magnitude of the GSI uranium source term.

(f) NIOSH has produced no records and no scientifically defensible assessment

of the uranium source term at GSI for years 1953 through 1958 of the covered period.

(g) NIOSH has no way to determine the percentages of the MCW uranium work

that was done in the Old versus the New Betatron facilities. As stated above, it is

inaccurate to merely state that doses from uranium in the two facilities were the same.

This fact has to be proven and it has not been by NIOSH to date.

(h) Precisely how NIOSH accommodates the fact that recycled uranium (RU)

with transuranic elements such as neptunium was used at Weldon Spring after 1962 is

not made clear in the January 2012 Allen-DCAS white paper.
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(i) MCW-Weldon Spring produced ingots and dingots from various uranium alloys

that have not been accounted for in dose models produced to date in either Appendix

BB Rev 0 (June 2007), the recent Allen white papers, or in TBD-6000 Rev 1.

(j) Mr. Allen’s January 2012 GSI white paper does not adequately account for the

medium (days) and longer lived fission products that 24-25 Mev Betatrons produce in

uranium as documented by peer reviewed journal articles and book chapters the

petitioners and site experts have provided to NIOSH, SC&A and the Board.

Model #9. Develop exposure model for steel activation from betatron.

Mr. Allen continues to underestimate the medium (days) and longer-lived

radioisotopes formed when >10 Mev photons activate various types of steel. Chapters

and papers on steel activation by Milwaukee School of Engineering physicist Vincent

Kuttemperoor, who addressed the Advisory Board about this topic, have been entered

into the official record. The paper by Guo and Paul Ziemer shows that medical Linac

particle accelerators that generate similar photon energy spectra to Betatrons also

activate metal surgical instruments. Both types of scientific literature establish the

presence of numerous activation radionuclides with half lives longer than NIOSH uses

to define the impact of steel casting activation.

The NIOSH dose estimates thus underestimate the dose to workers throughout

the GSI plant who handled the activated metal castings. The dose to Betatron operators

and layout men from the high nickel content x-ray film cassette steel are also

underestimated by NIOSH in a claimant unfavorable way. These underestimates need

to be corrected.

Model #10. Reconcile dose estimates with dose records.

The petitioners challenge NIOSH’s methodology and analysis as being

scientifically flawed for several reasons that follow:

(a) The film badge records are too limited to be representative of the entire GSI

work force. The Landauer dataset, according to NIOSH and SC&A, consists of film

badges from 89 Betatron and isotope workers, all male and all working in just one job,

radiographer.” Even for the Radiographers the film badge dataset is not inclusive of

Magnaflux operators. The GSI work force ranged between about 1200 and 4000

workers, with a significant number (10 to 15% at least) of the work force being female.
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(b) Allen states that Landauer provided NIOSH with 114 “control room badges”

that can be used to set limits for external exposure from the New Betatron. Elsewhere in

this critique we show that there never were any “control” badges stored in, or exposed

in, the true Betatron control room/s (there were two of them, Old Betatron and New

Betatron) that are where the Betatron operating console was located and used to

control the Betatron “cameras” in the shooting room next door. As we show in Section

D, through a clear drawing provided by GSI Betatron operator John Terry Dutko, and

confirmed by affidavit testimony from two of his colleagues who handled the film

badges, the film badges when not in use were actually stored away from the console

control room in an office (Dutko film badge location/position #1) and even farther from

the shooting room (Dutko film badge rack position #2). Thus the 114 “control room

badge” rading are not representative at all of the true console control room as Mr. Allen

states in his October 2010 nine page “Path Forward For GSI” original white paper.

(c) NIOSH lacks a valid pedigree for the GSI film badge data. They are unaware

of the details of the film badge distribution and collection processes. They do not know

who shipped the film badges to Landauer. There is no proof that Landauer film badge

reports were kept at GSI, or if they were, exactly where they were kept. All such GSI

company records related to the GSI film badge program have been destroyed or lost.

GSI co-petitioner McKeel wrote this on page 10 of his 7/29/09 critique of the

NIOSH evaluation report of GSI SEC-00105:

[32] p. 21 of 39, Section... Pedigree of General Steel Data mentions “...

data quality, credibility, reliability, representativeness, and

sufficiency.”

a) NIOSH-Landauer GSI film badge data 1964-66 are not quality

data as the measurements are confined to periods Betatron

workers (0.3% of work force) spent in the Betatron facilities,

credible (no feedback from supervisors so workers did not trust

their supervisors or management about the badge readings),

reliable (no evaluations of this factor), representative (89 of 3000

workers = 0.3% of a single job class in 1964 were badged) and

data was lost or destroyed for other Betatron and isotope only

1953-63 workers, who as a class were the only GSI workers who

were monitored individually part of their work period. (end quote)

(d) Dan McKeel, SEC-00105 co-petitioner, first contacted Landauer and talked to

two employees who informed him about the existence of some GSI film badges thirteen
GSI New Betatron Lead Shielded Door

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(13) months before NIOSH obtained their GSI dataset from Landauer in January 2009.

McKeel obtained only fragmentary quarterly data. However there were two especially

high badge readings from two GSI Betatron operators that were called to McKeel’s

attention by the researcher who found the GSI badge records at Landauer. She noted

the highest badge reading, for Morrell Peterson (deceased, not protected by the Privacy

Act of 1974), “was obtained in a short period of time.” Later, SC&A reported they had

evidence to show the two highest GSI film badge reports had been retracted. However,

despite our requests, NIOSH never produced these unredacted records or shared their

GSI film badge dataset. One of the men, now alive, stated recently he was not aware of

having gotten a high badge reading, but wondered why GSI advised him to seek

medical attention after he left their employ. See Section D for more details.

Petitioners, site experts, and GSI Betatron workers have provided evidence that

the highest GSI badge reading occurred during an incident with the small Co-60

sources that probably did overexpose a badge that was dropped and left overnight near

the exposed source. However, it is also likely, from the details of the incident we know

about, that the worker himself was also overexposed to an unknown dose.

(e) Betatron workers contend their badges did not detect all of their dose, and

hence it is unfair to use them to define the upper limit of dose, because workers

routinely removed their badges when working in parts of the GSI complex other than the

two Betatron facilities. NIOSH contends the badges limit Betatron external photon

doses. The GSI badge reports from Landauer do not report beta or neutron doses.

(f) New Betatron worker testimony has recently been given that film badges with

high readings were sometimes deliberately destroyed. It is unknown how often these

badge destruction events took place. Apparently there was some perception that

disgruntled workers might be “playing games,” as the reason the badges were

destroyed and probably were never delivered to Landauer to be read and recorded.

Section C of this Addendum contains more details.

(g) The petitioners challenge, and do not accept, that comparison of a cobalt-60

source that Mr. Allen states was disallowed under EEOICPA, with film badges

constitutes a valid scientific “reconciliation” of the disparate NIOSH and SC&A modeling

results to date. Most persons would say the film badge readings must be representative
GSI New Betatron Lead Shielded Door

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and agree ±10% with the computer models to be considered reconciled. This threshold

has not been met.

Section C. Miscellaneous Addenda to the main critique.

(a) GSI owned Ir-192 source term.

More documentation has been obtained from GSI Betatron supervisor Gillum

Burgess (deceased) on the GSI owned Ir-192 gamma source. The petitioners believe

emphatically that NIOSH, SC&A, the TBD-6000 work group and the Board have ignored

extensive eye witness GSI worker testimony that GSI owned and used an Iridium-192

source, that was different from the St. Louis Testing Ir-192 source that David Allen

describes in his January 2012 GSI white paper on Betatron operations. The new

information identifies the GSI Ir-192 as 10 to 20 Curies:

[Burgess & Hight e-mail exchanges about GSI Ir-192 source here]

From: jim burgess <illumbar6@sbcglobal.net>

Date: November 1, 2006 5:53:05 PM CST

To: John Ramspott <jwramspott@sbcglobal.net> ,

danmckeel2@aol.com

Subject: Fwd: Operations Document reply

The large castings were processed only in the old betatron except

for the pipes which were x-rayed using Iridium anywhere

necessary, but not routine except in primarily in the end of 10

building and sometimes in building number 9. The only Co60in

my time was the small "pill" in six building west end up against the

foundry core truck aisle on the west. (emphasis added, end quote)

Victor Hight replied by e-mail to Terry Dutko:

 Legend. E-mail from Terry Dutko to Dan McKeel transmitting

the e-mail message text shown on next page 18.
GSI New Betatron Lead Shielded Door

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(begin quote)

Dr. Dan-Just a reminder that the Iridium info about the (GSI) 10-

20 Curie Iridium and one-quarter Curie Cobalt-60 (sources) came

from Vic Height, Mountain Grove, Mo. Vic started in the fall of

1963, at GSI, worked in Magnaflux, then moved up to Isotopes. He

periodically worked in 6 building with Iridium and Cobalt,

shooting corner shots on rail truck frames. He also worked steady

midnights with Tom Crane at the old betatron while they were

going to school. Vick stated that Iridium was the weaker source,

penetration wise, and that it would take 2-4 hours, using Cobalt to

penetrate 2 inches of steel. Vic later worked at Magnaflux Co. and

worked all over the world with radiation. Terry Dutko

(end quote)

Note the new affiant refers to a 10 to 20 Curie GSI owned source that was

routinely used to inspect railroad car trucks in the 6 building Radiograph room (aka

Radiography facility).

(b) Additional neutron sources at GSI, especially from concrete activation.

Site expert John Ramspott and the petitioners have submitted scientific articles

by Carroll and others that show that chronic Betatron bombardment with >10 Mev

photons and neutrons, such as occurred in the GSI Old and New Betatron facilities,

cause prolonged activation of concrete and the production of significant secondary long

half-life exposure that results in additional worker exposures. The following e-mail

provides details:

 [Ramspott concrete and neutrons e-mail here]

The missing elements are :

"trace amounts of stable Europium, Cobalt, and Cesium that are

normally present in concrete in concentrations of a few parts per

million, or less, by weight". ( quotes from the Dr. Carroll Article)

According to Dr. Carroll's Article, they then become Isotopes, See

Below, please note the Half-life years too, considering the GSI
GSI New Betatron Lead Shielded Door

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workers went into the Betatron Vault in 5s ! (SC&A Report below) .

The men always mentioned dust. Anyone who has been around

concrete also knows that is a ongoing problem as well.

The proper, and I believe required procedure would be "to be

claimant favorable" and use the correct era, timeframe concrete

formulas, as described in the published article. OR Provide

documented proof that the elements mentioned did not exist at GSI.

PLUS:

Per the FUSRAP Cleanup data:

Concrete was "Scalped" from the Old Betatron, and removed

because of levels of radiation still existing (in 1993) concern.

That concrete was taken "in barrels I believe," to an approved

disposal site. Why remove concrete if there was no problem?

That was not free. Surely the extent of radiation would be on record.

OR is the concrete still available ?

DOE at GSI Cleanup----Note all of the concrete.

"Concrete Scalping" is actually mentioned in the Cleanup

Reports.

 Legend. Inside of concrete walled New Betatron Building in 1992 during the ORNL

 DOE cleanup. Railroad tracks run diagonally across the photo. Portions of the

 25 Mev Betatron x-ray beam directly and chronically irradiated the concrete.

 More information about concrete activation products is given on page 19.

The concrete neutron activation radioisotopes are identified in the Carroll paper as

follows:
GSI New Betatron Lead Shielded Door

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It can be seen that some of these isotopes would add to the dose that Betatron

building operators and assistants, electricians, railroad operators, chainmen handling

castings, and others working inside the facility would receive. As such, these doses,

even if small, must all be accounted for by NIOSH in dose reconstruction. This aspect

needs to be addressed in a revised Appendix BB.

(c) Radon in GSI buildings and above- and below ground tunnels has not

been factored into NIOSH internal dose calculations.

GSI, similar to many nuclear weapons facilities such as the Linde Ceramics plant

in New York, had an extensive system of underground tunnels and conveyor belts as

well as above-ground exit and entry rail tunnels to the Old and New Betatron facilities.

The above ground tunnels were how uranium and castings were transported into the

GSI Betatron facilities for NDT examination. Chainmen and train operators and Betatron

workers would surely be exposed to such radioactive radon gases. Workmen in other

parts of the GSI building complex (foundry, sand plant, buildings 6 through 10, etc.)

could also have been exposed to atmospheric radon.

Various maps and drawings of the GSI tunnel systems exist. To our knowledge,

neither NIOSH nor SC&A have conducted any research about radon flux at the GSI site.
GSI New Betatron Lead Shielded Door

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To our knowledge, no radon monitoring data exists for GSI and no radon model

for GSI has been developed by either NIOSH or SC&A.

Based on experience at sites such as Blockson, Texas City and Linde, radon

exposure at GSI must be assumed and must be dose reconstructed to comply with the

Act and with OCAS-IG-003 dose reconstruction internal NIOSH guidance.

(d) New affidavit evidence that no “control” film badges were ever kept in

the true Old or New Betatron console control rooms.

David Allen in his original October 2010 Path Forward for GSI paper spoke about “control

room film badges” (emphasis added), as follows on page 2 of 9:

(quote)

Film badges were exchanged weekly and kept in the New Betatron building when the

operator was not present. Also, control room badges were included for a number of

periods. The last control room badge was issued for the week of January 31, 1966

through February 6, 1966. The film badge report indicted this badge had been issued

starting in November 1963 and never exceeded 10 mrem in a week. Therefore, whatever

combination of radiographic exposure scenarios used to model doses from betatron

operations must result in no more than 10 mrem in the control room in 168 hours (1

week).

(end quote)

Note that David Allen in his October 2010 report clearly refers to control room

film badges in the GSI “New Betatron building.” He does not explicitly state whether

there were separate sets of control room badges from the Old Betatron building. Nor

does he state explicitly that the Landauer film badge records NIOSH obtained

distinguished the location—New or Old Betatron Building—where the purported “control

room” badge set of 114 badges was stored, nor does he state which actual building was

being monitored.

Note also that uses his concept of “control room badges,” which this sections

shows is an inaccurate assumption of fact, to limit the “...doses from betatron operations

must result in no more than 10 mrem in the control room in 168 hours (1 week).” In

light of the fact that, as will be shown in section D subsection (e), that control room

badges were not actually kept in the GSI true Betatron console control rooms, this

limitation of dose is based on a false factual premise. Therefore, it must be revised to

maintain NIOSH’s oft-stated position of being claimant favorable in all its scientific
GSI New Betatron Lead Shielded Door

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assumptions. This construction of the facts is the opposite, claimant adversarial by

limited assigned external photon dose.

two former GSI workers who handled the GSI film badges on their way to

Landauer refute the idea that any film badges were ever kept in the console room, the

true control room, where the actual Betatron control console was located. Those same

two badge handlers, in fact state categorically that they do not believe control badges

were kept. The obvious conclusion is that someone in GSI management fabricated the

114 film badges and sent them to Landauer to be recorded as control badges. As

stated, NIOSH does not have a complete, validated film badge data pedigree for any

GSI worker during the covered period.

 [Dutko control film badge affidavit here]

(begin quoted e-mail)

Dr. Dan—George Luber and Joe Pollo were basically saying they knew

of the function of the badges and where they should be kept-not that the

control badge was definitely there!

Don Piper & Ed Holshouser stated “ there were no control badges in the

film badges they handled.—Don Piper saying emphatically, “there was

no control badge in the film badges I handled.

I spoke with Ed Holshouser who first worked the film badge and

secretary job under Jim Burgess, Bruce Norris, and John McCrone-all

three being deceased and all three serving as Betatron Managers in that

progression. These were basically the people handed the film badge data

by Ed Holshouser.Ed was promoted from secretary and film badge

handler to film reader and foreman. Don Piper, followed Ed through the

same line of promotion. The jobs were considered company!

In speaking with Don Piper, Don stated “ there was film badges for all

Betatron And Isotope personnel, and a few badges for visitors, but NO

Control Badge! This was also verified by Ed Holshouser.

Film Badge location from 1953-1963—I don’t know of the location.

Film Badge location 1964-11/66---New Betatron—Location one showing

on the diagram—later moved to location 2-again showing on diagram.

I never saw any Control Badge in the actual Control Counsel Room(

control room) in the Old Or New Betatron at any time as long as I

worked there. The film badges were always stored in the areas I

designated by diagram.

Terry Dutko 24 & 25 MEV Betatron & Magnaflux

Operator—GSI 11/63 to 11/66

(end of quoted e-mail)
GSI New Betatron Lead Shielded Door

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The following map of the New Betatron building by former GSI Betatron operator

John Terry Dutko shows the locations of the true console control room and that both

areas #1 and #2 were film badges were moved and stored between 1964-1966 were

farther away from the Betatron skyshine compared to the true console control room.

[Dutko New Betatron map with FB locations here]

 LEGEND. New Betatron building drawing by ORNL/ DOE 1991 during the GSI cleanup.

Map has been annotated in red to show the true situation that existed 1964-1966 with

 GSI Radiographer film badges stored in locations (1) and (2)away from the Betatron

operating console area marked “control room” on this diagram. Source JTD 3/12.

(e) New affidavit evidence that some GSI film badges were deliberately

destroyed in the 1964-66 covered time period.

Recently obtained testimony from multiple former GSI Betatron operators and

supervisors challenges the pedigree (validity and integrity) of the Landauer GSI 1964-

1966 film badge data during the end of the covered period. There was no film badge

data for the 1953-63. Workers state that (a) some badges with high readings were

discarded.
GSI New Betatron Lead Shielded Door

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Here is the affidavit that backs up the foregoing analysis of facts:

 [Dutko destroyed film badge affidavit]

(begin affidavit quote)

3/2/12 2nd proof reading

Dr. Dan—I have been concerned about information concerning exposed

film from film badges stated to me by an individual whose job it was to

put new film in the individual badges once a week and monitor the film

badge system We were having breakfast in Maryville, Illinois at the Red

Apple.

Different individuals were talking about the old days at General Steel.

The subject came up of film badges worn by the Betatron Personnel, and

this individual that handled the film badges blurted out—“if a

film on the badges was exposed and they didn’t think it was legitimate,

we just THREW THE FILM AWAY”! I some months later heard this

same individual make the very same comment to me over the phone! At

the Red Apple, when this person made the comment, (I was sitting right

next to him), I asked him point blank—“HOW DO TYOU KNOW THE

DIFFERENCE BETWEEN A LEGITIMATE EXPOSURE AND A

CONTRIVED ONE!” I heard statements TWICE, on two different

occasions, from this person. I dislike reporting this and do not like to

incriminate anyone, but I believe they were Ordered to do this. I

understood, by the comments, that this was an accepted procedure. I

surely believe that my Betatron fellow operators who have died of

Cancer, would like for me and expect me to report this. MY question is---

-If the film badge system was monitored in this fashion, how could we

say we were dealing with any kind of accuracy with the records?

I also knew another operator who had a high reported dose, that was on

his records! I talked to his individual and asked him if he knew of this

exposure? He told me “That he was never informed of the exposure, and

wondered, upon leaving GSI, why they kept badgering him to take a

physical, even after leaving their employment!”

I John Terry Dutko, SWEAR THESE STATEMENTS TO BE

ABSOLUTLY TRUE AS IHEARD THEM> I question any and all validity

of the film badge records, because I believe them to be

definitely MANIPULATED! I AM Willing to Take a Lie Detector Test if

YOU WILL!

John T. Dutko—24 & 25 MEV Betatron & Magnaflux Operator

—General Steel Castings

(end affidavit quote)

Several notable facts emerge from this affidavit that deserve further emphasis:

(1) The affiant poses a reasonable question: if badges were destroyed arbitrarily,

then how does NIOSH rely on using these film badge data from Landauer as a gold

standard for delimiting doses at GSI.
GSI New Betatron Lead Shielded Door

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(2) The affiant direct testimony about the GSI Betatron worker with the second

highest film badge reading is also important. The statement is this person was never

told about and therefore did not know that his badge had showed an elevated dose

reading. Yet SC&A claims that Landauer received a retraction letter from the person’s

supervisor that by this testimony, must have been done without this person’s knowledge

or agreement. Since the unredacted GSI letters to Landauer have not been made

available to the petitioners and others most knowledgeable about these events—i.e.,

the direct eye witnesses—the veracity and authenticity of the alleged GSI dose

retraction letters to Landauer cannot be verified independently. The GSI petitioners,

advocates and former workers challenge the validity of the GSI “highest dose” retraction

letters on these grounds. We urge NIOSH and SC&A to investigate further, and not to

accept the retraction letters at face value.

(f). Dan McKeel found that Dr. Wilfred Konneker was alive, gave his address and

phone to SC&A, and urged that he be interviewed to find out first hand about the

radiation safety program he advised to be put in place at GSI at the time of the initial

AEC cobalt-60 sources application in 1962. Dr. Konneker was president of Nuclear

Consultants Corporation (NCC) that advised GSI and did a radiologic survey of the 6

building Radiography facility in 1962. That report was part of the McKeel NRC 2010-

0012 FOIA material. A call was made by SC&A and some information was obtained, but

McKeel and David Allen were not included as they had been on two recent GSI worker

interviews as agreed to by NIOSH and the TBD-6000 work group and DFO.

This was a mistake in the petitioner’s view, and an excellent opportunity to

retrieve valuable first-hand data on GSI source terms, safety program, and the building

6 Radiography facility was lost. It remains unclear whether many of the “on paper”

aspects of the GSI-NCC proposed safety program, including yearly written tests for

Radiographers, were administered. The weight of current testimony is the written safety

and technical proficiency tests were not given or taken. Many of the NCC safety

program guidelines are now known not to have been followed. An example is the

instruction that crane operators had to get permission from the main safety officer

whenever they were to bring a casting into the inner 6 building Radiography facility.

There is abundant worker testimony this did not happen.
GSI New Betatron Lead Shielded Door

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Section D. Attribution of scientific contributions of workers, site experts and

petitioners, a negative comment on NIOSH scientific etiquette:

It is important to call attention in the written record to the fact that NIOSH has

frequently minimized, ignored, or failed to cite the scientific contributions to the revision

of Appendix BB and the deliberations on SEC-00105 for the former GSI workers,

claimants, site experts and petitioners. The same has occurred in some SC&A GSI

document reviews as well.

Mr. Hinnefeld, his predecessor and OCAS Director Larry Elliott, or David Allen,

or anyone at DCAS for that matter, have never formally acknowledged that GSI copetitioner Daniel McKeel was the initial source of their knowledge about GSI film badge

data residing at Landauer, or the existence of 1,016 pages of GSI isotope source

information, that was provided in response a McKeel FOIA request to NRC (2010-

0012). When McKeel transmitted the NRC FOIA 2010-0012 request to the Public

Docket 140, he inserted a paragraph that provided suitable attribution for this major

contribution. That paragraph follows:

 [insert NRC FOIA attribution language here]
GSI New Betatron Lead Shielded Door

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Source URL: http://www.cdc.gov/niosh/ocas/pdfs/d140/mckeel.pdf

(end quote here)

Despite my admonition that redaction by NIOSH would be inappropriate given

that NRC redacted nothing in the FOIA 2010-0012 materials provided to Dan McKeel,

NIOSH nevertheless redacted many names in the above OCAS website posting,

including those of people known to be deceased in the FOIA index McKeel provided to

them.

No one has honored this request and properly acknowledged the initial source of

the 1,016 pages of GSI source term information that NRC later posted on its website.

Nor have the OCAS/DCAS sections of NIOSH ever formally acknowledged the

numerous contributions of site expert John Ramspott to their understanding of GSI

operations. To our knowledge, the elegant GSI workbook provided by John and his wife

Chris Ramspott (now deceased) to all members of the ABRWH, to NIOSH and to SC&A

has (a) not been included in the DCAS SRDB, and (b) has not ever been acknowledged

in the way it should have been to the Ramspotts. This 2005 work book document

contains visual data and information that has not been, but should have been,

incorporated into many GSI related NIOSH technical documents. McKeel and Ramspott

continue to provide the TBD-6000 work group, NIOSH and SC&A with information that

was available to them in the Ramspott GSI work book as early as 2005.

Many GSI workers believe their information has been “cherry picked” by the

Board, NIOSH and SC&A. That is, when information can be manipulated or used to

support the NIOSH, Board or SC&A’s position, it is used. However, helpful information

to the workers they themselves or from persons acting on their behalf, that the workers

believe is equally valid, is ignored or suppressed or minimized. Among the many

examples that could be cited:

(a) GSI workers believe their film badge data is incomplete and is not

representative of their full radiation doses;
GSI New Betatron Lead Shielded Door

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(b) GSI workers, site experts and the petitioners do not accept SC&A and NIOSH

analyses and “evidence” that the highest GSI film badge readings were false and should

have been retracted as proposed by SC&A based on secret interviews they held with

Landauer employees who now worked at SC&A (biased sourcing of information),

(c) GSI workers believe that radiation overexposures due to incidents were not

carefully recorded in NIOSH technical reports and were not given sufficient weight in

NIOSH’s reaching the conclusion that SEC-00105 should be denied;

(d) The GSI community resents the fact that NIOSH will not acknowledge to

primacy of eye witness, former worker testimony, as carrying greater weight than some

written documents that convey information favorable to the company. There is a

widespread perception, based on extensive personal experience and eyewitness

observations, that GSI possessed and used an 80 curie cobalt-60 source and a 10 to 20

curie iridium-192 gamma source for NDT activities during the covered period. NIOSH

relies on a GSI cobalt-60 license information to put the start date for using the same

source at 1968, beyond and outside of the covered period that ended in on

December 31, 1966.

Respectfully submitted:

Daniel W. McKeel, Jr., M.D.

GSI SEC co-petitioner

US Mail: P.O. Box 15

Van Buren, MO 63965

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com
McKeel Addendum 2: Allen January 2012 white paper

- 1 -

Addendum 2: McKeel Critique on the Allen-DCAS

January 2012 White Paper on GSI Betatron Operations

by Daniel W. McKeel, Jr., M.D.

March 9, 2012

GSI SEC-00105 co-petitioner Dan McKeel received the following e-mail message

from Ted Katz, DFO for the ABRWH, in his AOL Inbox on March 9, 2012 at 3:35 PM.

Item [1] -- E-mail message received from Ted Katz 3-09-2012:

From: tmk1@cdc.gov

CC: DanMcKeel2@aol.com

CC: jwramspott@sbcglobal.net

CC: eky1@cdc.gov

Subject: TBD 6000 WG meeting

File: AgendaTBD-6000WG3-15-2012.doc 28K

Date: Fri, Mar 9, 2012 3:35PM

Dear Dan and John:

I’ve just been on the phone with Paul and online with SC&A. Paul is concerned that the quantity

of information associated with the latest NIOSH GSI paper, including your review (Dan) and the

upcoming SC&A review, make it quite possible that the meeting next week will not be sufficient

– that we are likely to need a follow-up meeting, which Paul has asked me to schedule for as

soon as possible following –in March if possible. So I have sent a request to the Board members

and staff for possible dates, so that we can meet as soon as possible if need be. I’ll let you know

once I have a date. Furthermore, the SC&A review will not be delivered to the Board until

Sunday and will have to be PA-cleared Monday for delivery to you and John. I have asked that

the clearance be completed as early as possible on Monday. If the lateness of the SC&A report

proves a hindrance, that too would be addressed by a follow-on meeting, as would a more

thorough SC&A review of your latest materials.

Just want you to be aware of these late developments. I’ve attached the meeting agenda.

--Ted

Item [2] -- John Ramspott replied to Mr. Katz by e-mail on 3/9/2012 and Dan

McKeel replied to Ted Katz, John Ramspott, Josh Kinman and Dr. Ziemer on

3/9/112 at 11:09 PM as follows:
McKeel Addendum 2: Allen January 2012 white paper

- 2 -

Dear Ted and Dr. Ziemer,

I also appreciate this feedback. However, I must express my dismay that Dr. Anigstein,

by the lateness of his SC&A review, has once again placed us all in an awkward

position. I have to leave to drive the 170 miles to St. Louis from Van Buren on March 13,

and John and I will drive to Cincinnati to arrive March 14. So the lateness of Bob's PA

cleared report will guarantee that John and I have had no time to prepare a rebuttal. Re:

"if the lateness of the SC&A review proves a hindrance," it definitely impairs the work of

the work group and, indirectly, of the full Board as well in coming to closure on the

Appendix BB revision and a work group decision on SEC-00105.

This continual last minute delivery of long-scheduled SC&A work products related to the

GSI site is unfair to the GSI claimants whom we represent and to the GSI former

workers who have spent so much of their time providing good, accurate and new

information to NIOSH, to the TBD-6000 work group, to the full Board, and to SC&A. As

we have repeatedly stated, it is really the job of NIOSH and DCAS to do the necessary

background work to assemble accurate information for their GSI technical reports.

SC&A is tasked to review what NIOSH proposes in the ten new exposure models for

revising GSI Appendix BB. It was Bob Anigstein who asked that the upcoming meeting

be scheduled as late as March 15 to give him plenty of time to complete his review of

the January 2012 David Allen and DCAS white paper on GSI Betatron Operations.

John and I still plan to attend the Thursday, March 15 work group meeting in person.

 -- Dan McKeel 3/9/12

 --

In a message dated 3/9/12 9:32:33 PM, jwramspott@sbcglobal.net writes:

(quote)

Thanks for the update.

John

(end quote)

[3] McKeel reaction to the Katz 3/9/12 TBD-6000 work group feedback.

(a) The agenda Ted sent 3.9.12 is reproduced below:

ABRWH

Work Group on TBD-6000

March 15, 2012

8:30 a.m. EDT

Cincinnati Airport Marriott Hotel

 Conference Phone: 866-659-0537

Participant Code: 9933701
McKeel Addendum 2: Allen January 2012 white paper

- 3 -

AGENDA

Note: Lunch break at 12:00 noon. Adjournment no later than 3:00 pm.

1. Roll Call and Call to Order (Ted Katz and Paul Ziemer)

2. Introductory remarks and review of Agenda (Paul Ziemer)

3. Overview of NIOSH White Paper on doses from Betatron operations at GSI (Dave Alan)

4. SC&A review of NIOSH White Paper on doses from Betatron operations at GSI (Robert

Anigstein)

5. Petitioner’s comments and review of NIOSH White Paper(s) and other issues related to

the SEC Petition for GSI (Dan McKeel)

6. Discussion on all SEC issues

7. Work Group recommendations on SEC Petition for GSI

8. Adjourn

McKeel comment after reading the agenda on 3/9/12: This agenda does not make it

clear that the Allen (“Alan” is a misspelling) October 2011 white paper (GSI portable

sources, discussed at the previous work group meeting) and the January 2012 (GSI

Betatron Operations) Allen white paper, only address Appendix BB.

As was stated in the preceding section B, Mr. Allen has not yet addressed the

SEC issues that were stated to be addressed in the original “Path Forward for GSI”

document of October 2010. A TBD-6000 work group recommendation to deny the SEC,

thereby sustaining the NIOSH position, would be inappropriate without finally resolving

all outstanding SEC issues. Although Mr. Allen indicated he would do so in the ten new

models, the two deliverables have not addressed SEC issues per se, only Appendix BB

dose reconstruction issues. Stuart Hinnefeld, the current DCAS Director, made it crystal

clear to Dan McKeel the ten new NIOSH models would only address revising the June

2007 Rev 0 version of Appendix BB to Battelle TBD-6000 (next page).

DCAS Director Hinnefeld’s responses dated 8/9/11 to McKeel questions about

the purpose of the ten new NIOSH exposure models follows, for the written record:




McKeel Addendum 2: Allen January 2012 white paper1

Co-petitioner McKeel’s summary and conclusions:

There is considerable overlap between what NIOSH, the Board and SC&A

consider to be “dose reconstruction (“DR”) issues” as distinct from “SEC issues.” To my

knowledge, a clear bright line has never been drawn between them on the written

record by anyone. That is, there is no clear existing definition of what are “dose

reconstruction issues” or what are “SEC issues.”

Both DR and SEC issues involve establishing radiation doses using a variety of

techniques other than direct measurements of actual radiation doses that are delivered

to individual workers with defined jobs working in discrete, defined areas of an AWE or

DOE nuclear weapons facility. Those methods involve derivative techniques such as

use of surrogate data, use of “co-worker” models, use of computer models lacking real

data as validation, and mathematical contrivances such as the “photon-to-neutron ratio.”

All of these methods are used where real radiation measurement data is unavailable for

individual workers with a known job and known, established exposure parameters.

Both DR and especially SEC indirect dose calculation methods involve

tremendous degrees of uncertainty. Although “certainty analysis” has become a

subspecialty area of modern statistics, formal uncertainty analysis is rarely applied to

NIOSH radiation dose calculations.

The SEC rule states that NIOSH, in order to deny an SEC petition, must

establish that it can calculate a dose for “each and every member” of an SEC class.

Thus even SEC class “bounding doses” are individualized to a certain extent. The

actual wording of the EEOICPA act, and the 83.1-3 governing final rules for dose

reconstruction and SEC petitions are inexact in many areas, so the definition of

precisely where DR issues end and SEC issues begin is vague and indefinite at the

present time (March 2012).

Nevertheless, DCAS Director Hinnefeld’s 8/19/11 answers to Dan McKeels

questions about the purpose of the ten new NIOSH exposure models that are covered

in the preceding October 2011 and January 2012 white papers on portable GSI sources

and GSI Betatron operations leave no doubt these models were developed primarily to

 

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McKeel Addendum 2: Allen January 2012 white paper

revise Appendix BB. Mr. Hinnefeld states unequivocally that NIOSH has “no plans” to

2

revise its evaluation report on the GSI SEC-00105 petition. No new indication has

emerged since Mr. Hinnefeld’s responses were delivered to Dan McKeel in August of

2011.

Finally, as covered in the original McKeel Allen January 2012 critique and

Addendum numbers 1 and 2, the specific SC&A Findings that were stated by NIOSH to

be covered by the Path Forward for GSI have not been adequately resolved. Dan

McKeel’s prediction in November 2010 that the consideration by the TBD-6000 work

group of the Allen/DCAS GSI Path Forward would extend deliberations for months or

years has been borne out. The 3/9/12 e-mail from Ted Katz to Dan McKeel and John

Ramspott indicates that yet another work group meeting may be needed to consider all

of the NIOSH, SC&A and petitioner information about GSI. Although holding that

meeting in March was mentioned as a goal/possibility, as this is written no definite date

has been established. Important SC&A Findings about both Appendix BB and SEC00105 remain to be resolved. It also remains unclear when the TBD-6000 work group

and the full Board may vote on the GSI SEC.

Respectfully submitted,

Daniel W. McKeel, Jr., M.D.

P.O. Box 15 / #7 CR 301A

Van Buren, MO 63965

Phone: 573-323-8897

Fax: 573-323-0043

E-mail: danmckeel2@aol.com

 

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